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2008 (9) TMI 27 - AAR - Income Tax
Applicant provides clinical & bioanalytical services to various pharmaceutical companies including some Indian companies – held that consideration received by applicant would be its business income - In view of Article 7 read with Article 5 of DTAA, such income can be taxed only if the applicant has a Permanent Establishment in India - fee received by applicant is in the nature of ‘business profits’ under Article 7 & the same is not taxable in India as the applicant does not have a PE in India